Today we’ve published our version of the Senior Managers and Certification Regime outlining the responsibilities of our senior people and how our organisation is arranged and governed.

In 2016 a new individual accountability regime for banks – the Senior Manager and Certification Regime (SMCR) – was introduced by the FCA and the PRA. It was later adopted for insurers and will be extended to all other regulated firms in December 2019. 

The regime is designed to make sure there’s clear accountability at the senior levels of an organisation. The aim is to make individuals more accountable for their responsibilities, conduct and competence.


We’re not obliged to do so, but we’ve chosen to create our own version of the regime. Individual accountability is one of our core values so implementing and publishing an SMCR is in line with that and supports our strategic aim to emulate best practice within financial services.

What we’ve included in our SMCR

We’ve chosen to implement all aspects of the accountability regime that are relevant to us rather than directly replicate the FCA or PRA rules. 

This includes producing a map of responsibilities to show where responsibilities lie at a senior level. Alongside this are statements of responsibilities that set out each senior manager’s individual responsibilities and our processes for certifying key people.

The aim of our SMCR is to help us:

  • Hold our senior people accountable for what they’re responsible for
  • Make sure senior managers and certified persons are fit and proper to carry out their roles, developing our focus on skills, capability and conduct
  • Nurture our culture of personal accountability, which enables all individuals, not just senior managers, to speak out when they see harm or potential harm 

“Implementing our version of the SMCR will also help clarify and enhance personal accountability and support the importance of a clear and effective governance structure,” said Dana Grey, our Director of Legal, Compliance & Ethics. 


“We’re looking forward to embedding this throughout the coming year in order to enhance our service to members and stakeholders.”

Download our Senior Managers and Certification Regime